Studio: GDPR requirements before user sign-up
If your business is based in the European Union (EU), or you process the personal data of individuals in the EU, the General Data Protection Regulation (GDPR) affects you.
When relying on consent as your legal basis, the GDPR says the consent you obtain must be freely given, specific, informed, and unambiguous. You also must clearly explain how you plan to use their personal data.
When you launch your marketing campaign using Studio (Branded Mini-Games DIY Studio), our tools include game customisation, sign-up/sign-in tool, social sharing integration, leaderboard, analytic integration and other sub-subprocessor integration such as mailchimp. You may want to give out prizes to highly ranked individuals on a leaderboard or randomly selected winner. OR just the simple usage of a leaderboard shall require users to sign-up with their personal information. Thus, you are required to obtain consent from users for the personal information they will provide for such events. You need to provide your own privacy policy (GDPR compliant version) and you need to add the following text, mentioning Branded Mini-Games (Emoji Games) as the data processor in the field of Privacy Policy.
(quick example)
“We use Branded Mini-Games as our game marketing automation platform. By playing the Game, you acknowledge that the information you provide will be transferred to Branded Mini-Games for processing in accordance with their Privacy Policy.“
We take customer privacy and security very seriously, which is why we offer a data processing agreement for EU/EEA and Swiss customers or non-EU/EEA and Swiss customers processing data on behalf of EU/EEA and Swiss individuals, in addition to our publicly posted Privacy Policy. This data processing agreement (DPA) has been agreed by you when you signed up with our Branded Mini-Games Terms of Use. Branded Mini-Game acts as your Data Processor and you act as the Data Controller who publishes your own branded mini-game campaign, targeting your audience playing games powered by Branded Mini-Game services. Please check this DPA carefully to learn your liabilities according to the GDPR.
Note: Branded Mini-Games offers tools and information as a resource, but we don’t offer legal advice. We recommend you contact your legal counsel to find out how the GDPR affects you.